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  • August 17, 2018

    Manafort Judge Talks Threats In Not Releasing Jurors' Names

    The Virginia federal judge overseeing the Paul Manafort trial on Friday revealed he has received threats during the case and expressed concern that revealing the names of jurors deliberating the fate of the former Trump campaign chair could put their “peace and safety” at risk.

  • August 17, 2018

    King & Wood Mallesons Nabs Ex-Cahill Gordon Tax Expert

    King & Wood Mallesons LLP announced it has hired a former Cahill Gordon & Reindel LLP tax partner experienced in investments, capital markets and private investment funds for the firm’s New York office to boost its U.S. operations.

  • August 17, 2018

    Foreign Entity Given 120 Days To Elect As Disregarded

    The Internal Revenue Service released a private letter ruling Friday, granting a foreign entity extra time to elect as a disregarded entity for federal tax purposes. 

  • August 17, 2018

    Foreign Entity Given More Time To Elect As Disregarded

    The Internal Revenue Service released a private letter ruling Friday granting a foreign entity extra time to elect as a disregarded entity for federal tax purposes. 

  • August 17, 2018

    Taxpayer Advocate Blasts IRS On Taxing Foreign Earnings

    The Taxpayer Advocate Service criticized the Internal Revenue Service’s application of the transition tax, stating that its interpretation of the law was contrary to congressional intent and could materially damage corporations, in a blog written Thursday.

  • August 17, 2018

    IRS Updates List Of Priority Guidance Projects For Q4

    The Internal Revenue Service on Friday released its fourth-quarter update to the 2017-2018 Priority Guidance Plan, which added 12 projects to the agency’s list of the top tax provisions in need of administrative clarification.

  • August 17, 2018

    Foreign Entity Gets 120 Extra Days To Elect As Partnership

    The Internal Revenue Service on Friday released a private letter ruling granting a foreign entity extra time to elect as a partnership for federal tax purposes.

  • August 17, 2018

    Ky. Breaks From Federal Treatment Of GILTI, Tax Dept. Says

    A new Kentucky law does not consider global intangible low-taxed income as taxable income for state purposes and will not allow a deduction for GILTI granted by the federal tax overhaul, according a recent memorandum from the state Department of Revenue.

  • August 17, 2018

    Exempt Org Tax Pro Group Provides Feedback On TCJA Changes

    The TEGE Exempt Organizations Council, a group composed of tax practitioners, on Friday sent recommendations to the Internal Revenue Service and U.S. Department of the Treasury for guidance related to the federal tax overhaul.

  • August 17, 2018

    Expat's Challenge To US-Canada Tax Treaty Fails In NC Court

    A treaty with Canada directing the Internal Revenue Service to collect taxes on Canadian taxpayers living in the U.S. is not unconstitutional, a North Carolina federal court has ruled in dismissing a claim for a $125,000 refund.

  • August 17, 2018

    Taxation With Representation: Akin Gump, Wachtell, Kirkland

    In this week’s Taxation With Representation, Diamondback snapped up Energen for $9.2 billion, Federal Street Acquisition Corp. bought Universal Hospital Services for $1.7 billion, Cabot Microelectronics Corp. bought KMG Chemicals for $1.6 billion and Best Buy acquired GreatCall for $800 million.

  • August 17, 2018

    Finance Committee Plans Hearing To Examine Treasury Nominee

    The U.S. Senate Finance Committee will hold a hearing Wednesday to consider the nomination of Michael Faulkender to be assistant treasury secretary for economic policy, according to a Thursday announcement from the panel’s chairman, Sen. Orrin Hatch, R-Utah.

  • August 17, 2018

    Changes To India APA Rules Should Facilitate More Deals

    India recently relaxed its requirements for reaching advanced pricing agreements with other countries to make it easier to facilitate the deals, but other factors, including the country’s improved relationship with U.S. tax authorities, may do more to grease the wheels.

  • August 17, 2018

    US, Germany To Exchange Corporate Tax Data

    German and American officials announced Thursday that they were exchanging information on companies’ tax activities in line with internationally accepted guidelines from the Organization for Economic Cooperation and Development.

  • August 17, 2018

    Withholding Tax May Solve Digital Problem, Say Profs

    The seemingly intractable problem of how to tax worldwide online services could be fixed by judicious use of withholding taxes, concludes a study produced for the International Fiscal Association.

  • August 17, 2018

    Denmark Widens £1B Tax Fraud Suit, Includes UK City Firms

    Denmark’s tax authority has filed a suit at the High Court in London against 71 individuals and companies, including many in the financial services sector, which it alleges took part in a massive multinational fraud to cheat the Danish government out of £1 billion ($1.3 billion) in reimbursed taxes.

  • August 16, 2018

    Utah Tax Commission Offers Pay Plan On Deferred Foreign Income

    In reaction to the Utah Legislature passing a bill on deferred foreign income in mid-July, the state's tax commission has said taxpayers with previously unreported foreign income can pay state corporate tax on that income in installments over eight years.

  • August 16, 2018

    Treasury Publishes Rule On Alcohol Excise Tax Refunds

    The U.S. Department of the Treasury published an interim rule effective Thursday that expands the authority of U.S. Customs and Border Protection to refund excess duties and taxes imposed on distilled spirits, wine and beer, to reflect changes in the recent federal tax overhaul.

  • August 16, 2018

    General Avoidance Rules Cause More Problems, Study Says

    Generalized statutory blocks on tax avoidance often do more harm than good, potentially leaving taxpayers uncertain about their liability, concludes a new study by the International Fiscal Association.

  • August 16, 2018

    German Prosecutors Secure Conviction In Massive VAT Scheme

    German prosecutors announced Wednesday that they had earned a conviction following the breakup of a record value-added tax fraud scheme.

Featured Stories

  • Changes To India APA Rules Should Facilitate More Deals

    No Photo Available

    India recently relaxed its requirements for reaching advanced pricing agreements with other countries to make it easier to facilitate the deals, but other factors, including the country’s improved relationship with U.S. tax authorities, may do more to grease the wheels.

  • Altera Withdrawal Highlights Warring Transfer Pricing Rules

    Molly Moses

    The Ninth Circuit’s withdrawal of the government’s win in a cost-sharing suit against Altera threw a set of IRS regulations into muddied waters, but it wasn’t the first time courts had struggled to reconcile fundamental contradictions within the agency’s transfer pricing rules.

  • 'Come Loaded For Bear' Before Manafort Judge, Attys Say

    No Photo Available

    Lawyers who have appeared before the Virginia federal judge overseeing the fraud trial of former Trump campaign chair Paul Manafort offer two pieces of advice for arguing in his courtroom: Be prepared. Be concise.

Expert Analysis

  • Why 25% Foreign-Owned Blocker Corps. Must File Form 5472

    Brad Wagner

    The IRS has recently become very aggressive in asserting penalties for failing to file a Form 5472 — used to identify potential tax issues with regard to transactions between a U.S. corporation and related foreign shareholder, says Brad Wagner of Wagner Duys & Wood LLLP.

  • Tax Enforcers Unite Against International Tax Crime

    Kyle Womboldt

    In light of the launch of the Joint Chiefs of Global Tax Enforcement alliance against transnational tax crime and money laundering, it is more important than ever for corporations and professional services firms to carefully manage their exposure to higher risk clients and business activity, say Kyle Wombolt and Jeremy Birch of Herbert Smith Freehills LLP.

  • Controlled Foreign Corp. Restructuring For US Taxpayers

    Carl Merino

    The Tax Cuts and Jobs Act introduced a number of changes targeting U.S. companies that were intended to reduce incentives to shift earnings overseas. However, these provisions, which have had a disparate impact on U.S. citizens who own closely held companies overseas or are beneficiaries of offshore succession planning schemes, will force a re-examination of many existing structures for affected U.S. taxpayers, say Carl Merino and Dina Kapur Sanna of Day Pitney LLP.

  • Pre-Clearance Not An Option As OVDP Deadline Looms

    Jeffry Erney

    As the end nears for the IRS offshore voluntary disclosure program, the deadline for taxpayers to confirm their eligibility has already passed. Would-be OVDP applicants must decide for themselves whether to take the risk of filing an application without a pre-clearance letter, say Jeffry Erney and Peter Anthony of Dentons.

  • How Taxpayers Are Taking To Tax Reform So Far

    Nickolas Gianou

    The effects of last year’s tax overhaul, the most significant since 1986, have not been as drastic as some expected. Still, taxpayers have begun to adjust and a number of significant trends are emerging, say Nickolas Gianou and Sally Thurston of Skadden Arps Slate Meagher & Flom LLP.

  • Combine Business And Vacation Travel For Tax Savings

    Steven Packer

    Summer is well underway and you may be considering combining a business trip with vacation plans or may have already traveled for both business and pleasure purposes. Gregory Smith and Steven Packer of Duane Morris LLP discuss a few strategies to help you achieve the greatest tax benefit from properly combining and documenting business and personal travel.

  • GILTI Expands On US Anti-Deferral Mechanisms

    Patrick McCormick

    Without anti-deferral mechanisms, U.S. taxpayers could inappropriately source income to foreign jurisdictions to circumnavigate domestic taxation. Long-standing rules like Internal Revenue Code Section Subpart F have sought to combat such actions. While the IRS may intend the newly created "global intangible low-taxed income" provision to also combat income-shifting, its application will move far beyond the intangible, says Patrick McCormick of Drucker & Scaccetti.

  • IRS Proposed Regs Clarify Transition Tax

    Elizabeth Zanet

    Last week, the IRS issued lengthy proposed regulations relating to the Section 965 transition tax applicable to U.S. shareholders holding interest in a deferred foreign income corporation. Elizabeth Zanet and Rusudan Shervashidze of Ruchelman PLLC discuss the impacts on tax rate computation, domestic pass-through entities, previously taxed income and acceleration events for deferred payments.

  • More Transfer Pricing Disputes And Other Altera Aftermath

    Kristin Garry

    The recent Ninth Circuit opinion in Altera Corp. v. Commissioner of Internal Revenue reaffirms the increasing significance of general administrative law principles in tax cases and marks a substantial departure from the arm’s-length standard for U.S. transfer pricing analysis for the past 80 years, say attorneys at Shearman & Sterling LLP.

  • What It Means To Be A US Beneficiary Of A Foreign Trust

    Rusudan Shervashidze

    In today’s global environment, it is not surprising to find a beneficiary of a foreign estate or trust living in the United States. However, it is important for U.S. beneficiaries to understand the repercussions of direct or indirect ownership of foreign corporations taxed as passive foreign investment corporations under U.S. law, say Rusudan Shervashidze and Nina Krauthamer of Ruchelman PLLC.